To Members of the Traffic Mobility Review Board: Carl Weisbrod, Chair, John Banks, John Durso, John Samuelson, Elizabeth Velez, and Kathryn Wylde
Cc: Governor Kathy Hochul, andJanno Lieber, MTA Chair and CEO

We, the Congestion Pricing Now Coalition, write to express our continued support for New York’s Central Business District (CBD) Tolling Program and to thank the members of the Traffic Mobility Review Board (TMRB) for your service.

We would like to express our strong support for the use of bridge and tunnel toll credits to be included as part of the TMRB’s recommendations. Crediting bridge and tunnel tolls can significantly reduce excess travel, particularly through environmental justice communities. If New York’s congestion pricing program is to become the model for the nation, rather than a cautionary tale, it is essential that the TMRB, State, and MTA ensure the program is implemented in a way that is equitable, and such that no communities are disproportionately impacted by toll shopping.

As it currently stands, about two-thirds of drivers enter the CBD for free, while about a third pay a variety of different toll rates depending on the route used. This increases traffic congestion in neighborhoods that host the free crossings, causing substantial health and environmental impacts. While much of the focus of toll credits has been on the Hudson River crossings, we believe that toll shopping could be even more pronounced on the East River crossings, with congestion and vehicular emissions potentially increasing in neighborhoods surrounding the currently free bridges. Ideally, the congestion pricing program would eliminate toll shopping altogether such that all entry points into the CBD are charged the exact same amount. Short of that, we must at least minimize the delta among CBD-bound tolls to the greatest extent possible.

In order to minimize toll shopping – the elimination of which was among the primary goals of congestion pricing to begin with – the congestion pricing program will need to apply toll credits, or off-sets, to reduce the delta between toll crossing as much as possible. This will require looking at the total cost of trips into the CBD, including MTA and Port Authority tolls, rather than simply looking at the congestion pricing charge in isolation. Working to achieve cost equalization between bridges and tunnels entering the Manhattan CBD will allow drivers to use the most efficient crossing without the need for toll shopping, allowing for a more even, equitable flow of traffic into the area and less local climate air pollution to boot.

Additionally, our coalition strongly recommends a per-ride surcharge on For-Hire Vehicles (FHVs) paid by the passenger, rather than a once-per-day toll paid by the driver. FHVs are a significant cause of congestion and vehicular emissions within the central business district. However, the Federal Highway Administration (FHWA) has determined that FHV drivers are an important environmental justice (EJ) community. As a result, the Environmental Assessment approved by FHWA limits tolling on FHVs to once per day. Our coalition firmly believes that eliminating the once-per-day toll and replacing it with a per-ride surcharge, charged to passengers, will do far more to reduce congestion, protect drivers, and generate revenue for public transit. However, our coalition believes that taxis should be exempt from the proposed per-trip surcharge, given they have already been hit hard by the collapse of medallion values and the unbridled introduction and establishment of app-based FHVs throughout the city.

We thank you for your consideration and dedication to this important issue.

Thank you,
Congestion Pricing Now
[email protected]
congestionpricingnow.org